13 August 2007 Internal T.I. 2007-0228901I7 - Investment Tax Credit

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

Principal Issues: (1) Meaning of "sale" in the expression "manufacturing or processing goods for sale" in paragraph (c) of the definition of qualified property in ITA 127(9). (2) Whether the taxpayer's shop expansion and XXXXXXXXXX that otherwise would meet the conditions for qualified property are used for the purpose of manufacturing or processing goods for sale

Position: 1) The meaning of sale is to be interpreted taking into account the sale of goods legislation and common law as decided by the SCC in Will-Kare Paving and Construction Ltd 2000 DTC 6467, and not in a literal sense as decided by the FCA in Nowsco Well Services Ltd, 90 DTC 6312, and Halliburton Service Ltd, 90 DTC 6320. (2) No position. General comments

Reasons: (1) Will-Kare Paving and Construction Ltd, 2000 DTC 6467. (2) Insufficient information

 									August 13, 2007

	XXXXXXXXXX 							HEADQUARTERS
	Auditor / Audit Division				Income Tax Rulings
	XXXXXXXXXX  TSO	   					Directorate
									James Atkinson CGA
(519) 457-4832

									2007-022890

XXXXXXXXXX
Subsection 127(5) of the Income Tax Act - Investment Tax Credit

This is in response to your memorandum of March 23, 2007, concerning whether XXXXXXXXXX's shop expansion and XXXXXXXXXX are eligible for the investment tax credit (ITC) on the basis that they are "qualified property" as defined in subsection 127(9) of the Income Tax Act ("Act").

The facts as we understand them are that:

1. XXXXXXXXXX is a mechanical contractor, situated in XXXXXXXXXX.

2. XXXXXXXXXX is a member of various industry associations XXXXXXXXXX.

3. Prior to XXXXXXXXXX did not have fabrication facilities. XXXXXXXXXX offered the same services described above with the exception of fabrication. Basically, XXXXXXXXXX installed and repaired equipment obtained from arm's length fabricators. In XXXXXXXXXX an office and shop were constructed. XXXXXXXXXX did not claim ITCs on the shop in XXXXXXXXXX. The shop is located in the same building as the offices. The shop occupies more space than the offices.

4. In the XXXXXXXXXX taxation year, XXXXXXXXXX added a shop expansion, which cost $XXXXXXXXXX , to class 1 of Schedule II of the Income Tax Regulations. In the XXXXXXXXXX taxation year XXXXXXXXXX also added XXXXXXXXXX, among other items, which cost $XXXXXXXXXX, to class 43 of Schedule II of the Income Tax Regulations.

5. XXXXXXXXXX claimed the subsection 127(5) ITC on the XXXXXXXXXX shop expansion and XXXXXXXXXX on the basis that the plant and equipment were qualified property within the meaning of subsection 127(9) of the Act.

6. An analysis of labour costs incurred by XXXXXXXXXX indicates that the company employed XXXXXXXXXX persons in XXXXXXXXXX and XXXXXXXXXX in XXXXXXXXXX. Approximately XXXXXXXXXX% of the workforce is employed in positions relating to fabrication whereas the balance work in the field performing repairs, maintenance and installation services, consistent with XXXXXXXXXX's reported revenue streams.

7. Overall revenues of XXXXXXXXXX have increased since constructing and expanding the fabrication shop. However, the revenue generated from the shop is only a small portion of total revenues. The majority of XXXXXXXXXX's revenues come from national maintenance agreements, repairs and installations.

8. Typically XXXXXXXXXX receives a request for quote (RFQ) from one of their regular customers. XXXXXXXXXX submits a quote, and if successful on the bid, the customer issues a purchase order (PO) for the amount of the quote. In many cases, XXXXXXXXXX does not sign a contract in addition to the PO. PO's typically state that XXXXXXXXXX, "fabricate, supply and install" something. PO's usually do not provide a breakdown between the fabrication and installation. Further, XXXXXXXXXX usually does not obtain two PO's, i.e., a PO for the fabrication, and another PO for the installation.

9. An analysis of XXXXXXXXXX jobs by category (fabrication only, fabrication and installation, installation only and other) based on an analysis of the descriptions stated on PO's indicates that the majority of taxpayer's revenues were contracts for fabrication and installation, installation only, or national maintenance agreements (NMA's).

XXXXXXXXXX.

XXXXXXXXXX reviewed the CRA analysis and came up with slightly different numbers. The discrepancy between CRA's analysis and XXXXXXXXXX 's analysis is due to the fact that XXXXXXXXXX split a few PO's between fabricate & installation as if XXXXXXXXXX had two separate PO's.

10. XXXXXXXXXX also provides repairs and maintenance services, including NMA's. During XXXXXXXXXX obtained NMA's with various XXXXXXXXXX. The duration of these NMA's was approximately XXXXXXXXXX years. XXXXXXXXXX successfully bid a total of $XXXXXXXXXX for XXXXXXXXXX NMA's with XXXXXXXXXX to cover the period XXXXXXXXXX. Therefore, the NMA's made up a significant portion of XXXXXXXXXX's revenue, or approximately XXXXXXXXXX % on an annual basis. The majority of the billings under the NMA's are for XXXXXXXXXX's labour.

11. An analysis of XXXXXXXXXX's largest contract during the audit period (i.e., their contract with XXXXXXXXXX) indicates the following allocation of cost: XXXXXXXXXX.

12. A further significant contract analyzed (job XXXXXXXXXX ) was with XXXXXXXXXX. This job was very labour intensive and as such the billings were primarily for field labour. Only a small portion (approx. XXXXXXXXXX %) of the hours billed were for shop fabrication hours. Accordingly, shop hours were ancillary to field labour.

13. You have concluded that XXXXXXXXXX's activities do not constitute "construction" as described in paragraph c of the definition of "manufacturing and processing" found in subsection 125.1(3) of the Act.

As we understand it, you are concerned about two issues. The first issue is whether paragraph (l) of the definition of "manufacturing or processing" in subsection 125.1(3) of the Act is to be taken into account in the interpretation of the expression "manufacturing or processing" found in the definition of "qualified property" in subsection 127(9) of the Act.

The second issue to be resolved is whether the shop expansion and XXXXXXXXXX are used by XXXXXXXXXX primarily for the purpose of manufacturing or processing goods for sale, which is an eligible activity referred to in subparagraph (c)(i) of the definition of qualified property in subsection 127(9). You are satisfied that all the other conditions in the definition of qualified property are otherwise met. In particular, your concern is the proper interpretation of the word "sale" in the expression "manufacturing or processing goods for sale".

Your Opinion

In your view, paragraph (l) of the definition of "manufacturing or processing" in subsection 125.1(3) of the Act is not relevant in the interpretation of the expression "manufacturing or processing" found in the definition of "qualified property" in subsection 127(9) of the Act. You stated in your referral memorandum:

In this case 125.1(3)(l) does not apply to the definition of "qualified property". Paragraph (l) denies the MP&P deduction to corporations that earn less than 10% of their gross revenues from the manufacturing or processing of goods for sale. As a result of the omission of this paragraph from the definition in 127(11) we submit that it was intended that eligibility for ITC's be determined on an individual asset basis. I.e. it is necessary to test each individual asset to determine whether that asset is primarily used in manufacturing. E.g. Corporation A earns 5% of its revenue from manufacturing. However, 100% of the revenue earned from Asset M is from manufacturing. It is our opinion that Corporation A would not qualify for the MP&P deduction, but Asset M may be eligible for ITC's.

It is your view that XXXXXXXXXX does not manufacture goods for sale; that is, manufactured goods that XXXXXXXXXX produces are supplied to customers primarily through contracts for work and materials, not through sale. Based on the similarities between XXXXXXXXXX 's situation and that in Will-Kare Paving & Construction Ltd, 2000 DTC 6467 (SCC), you have concluded that the expenditures for the shop expansion and XXXXXXXXXX , as described in 4 above, do not qualify for ITCs under subsection 127(5).

XXXXXXXXXX Position

XXXXXXXXXX is represented by XXXXXXXXXX . The representative is of the view that paragraph (l) of the definition of "manufacturing or processing" in subsection 125.1(3) of the Act is not relevant in the interpretation of the expression "manufacturing or processing" found in the definition of "qualified property" in subsection 127(9) of the Act.

XXXXXXXXXX's representative has taken the position that the restrictive meaning given to "sale" by the SCC in Will-Kare and the earlier decision of the Federal Court - Trial Division (FCTD) in Crown Tire Service Ltd, 83 DTC 5426 (FCTD), does not apply in XXXXXXXXXX's situation. This is because in Will-Kare and Crown Tire there was no discrete and identifiable good prior or contemporaneous to the provision of the service, whereas XXXXXXXXXX manufactures discrete and identifiable goods (e.g., XXXXXXXXXX). The circumstances of XXXXXXXXXX are distinguishable from the fact pattern in those cases and are more comparable to the decisions in Halliburton Services Ltd., 90 DTC 6320 (FCA), and Nowsco Well Services Ltd, 90 DTC 6312 (FCA), where the taxpayer produced a specialized product for its customers as well as providing certain services connected therewith. Consequently, XXXXXXXXXX's equipment fabrication operation, including the fabrication shop, XXXXXXXXXX and other equipment, should be viewed as "manufacturing goods for sale" regardless of the form of the contract with the customer and the subsequent provision of services connected therewith.

Our Comments:

ITC entitlement rests upon a determination of whether XXXXXXXXXX acquired "qualified property." As defined in subsection 127(9) of the Act, qualified property includes property that is a prescribed building or prescribed machinery and equipment to the extent it is acquired after June 23, 1975 and meets certain other conditions. Paragraph (c) of the definition of qualified property requires that the property must be acquired by the taxpayer primarily for use by the taxpayer in Canada for certain eligible activities, one of which is the manufacturing or processing ("M & P") goods for sale or lease. Lease is not an issue in XXXXXXXXXX 's case and will be ignored in our discussion below.

We share your opinion that paragraph (l) of the definition of "manufacturing or processing" in subsection 125.1(3) of the Act is not to be taken into account in the interpretation of the expression "manufacturing or processing" found in the definition of "qualified property" in subsection 127(9) of the Act.

The preamble of subsection 125.1(3) states that the definitions in the subsection apply in section 125.1 of the Act. Accordingly, the definitions in subsection 125.1(3) can be used for purposes of the definition of qualified property in subsection 127(9) only to the extent that the wording of a tax provision requires it. In this regard, subsection 127(11) provides interpretative rules regarding the activities to be included in or excluded from "manufacturing or processing" for purposes of the definition of qualified property. In particular, paragraph 127(11)(a) indicates that, for the purposes of the definition of qualified property, certain activities described in specific paragraphs of the definition of "manufacturing or processing" in subsection 125.1(3) are excluded (those listed in paragraphs (a) to (e) and (g) to (i)) and that specific other paragraphs of that definition are to be read in a certain manner (paragraphs (f), (j) and (k)). Since paragraph 127(11)(a) does not mention paragraph (l) of the definition of "manufacturing or processing" in subsection 125.1(3), such paragraph is not taken into account in interpreting qualified property in subsection 127(9).

The other issue that arises in your referral concerns the meaning to be given to "sale" in the expression "manufacturing or processing" in the definition of qualified property.

There had developed over the years two divergent interpretations of the activities that constitute manufacturing or processing of goods for sale or lease. On one hand were the decisions in Crown Tire and Hawboldt Hydraulics (Canada) Inc., 94 DTC 6541 (FCA), wherein the Court referred to common law and provincial sale of goods law in defining the scope of the provisions of the Act dealing with manufacturing and processing. A second line of authority evolved as a result of the decisions in Halliburton and Nowsco. This second line of authority declined to apply statutory and common law sale of goods rules but advocated a literal construction of the word "sale", such that any transfer of property manufactured by a taxpayer to a customer for a consideration, regardless of the nature of the contract between them, would amount to a sale within the meaning of the legislation. Under this broader interpretation of sale, the provision of a service incidental to the supply of a manufactured or processed good would not preclude a taxpayer from receiving the benefit of the manufacturing and processing incentives.

The divergence between the above two lines of authority was settled by the majority decision of the SCC in Will-Kare. In Will-Kare the taxpayer operated a paving business. It paved driveways, parking lots, and roads for both commercial and residential clients. The taxpayer initially purchased asphalt, but in 1988 constructed its own asphalt plant. Subsequently, the taxpayer used 75 percent of the asphalt production from the plant in its own business and 25 percent was sold to third parties. In reporting its income for its 1988, 1989, and 1990 taxation years, Will-Kare claimed M & P incentives, including ITCs. At issue was whether the taxpayer's plant was acquired to be used in Canada primarily for manufacturing or processing goods for sale or lease. While it was recognized that Will-Kare's plant was used to manufacture or process a good, that being asphalt, the issue was whether the use of the asphalt in its paving business involved a "sale", considering that the term "sale" is not defined in the Act. In Will-Kare, the SCC ruled that the principles set out in the Crown Tire and Hawboldt cases are to be followed. Mr. Justice Major (L'Heureux - Dubé, Iacobucci and Bastarache, J. J. concurring) stated in Will-Kare at 6473 and 6474:

[29] Notwithstanding this absence of direction, the concepts of a sale or a lease have settled legal definitions. As noted in Crown Tire and Hawboldt Hydraulics, Parliament was cognizant of these meanings and the implication of using such language. It follows that the availability of the manufacturing and processing incentives at issue must be restricted to property utilized in the supply of goods for sale and not extended to property primarily utilized in the supply of goods through contracts from work and materials.
...
[33] The technical nature of the Act does not lend itself to broadening the principle of plain meaning to embrace popular meaning. The word sale has an established and accepted legal meaning.
[34] Will-Kare's submissions essentially advocate the application of an economic realities test to the interpretation of what constitutes a sale for the purpose of the manufacturing and processing incentives. However, as noted above, in the absence of express legislative direction to the contrary, I view the incentives' reference to the concepts of sale and lease as importing private law distinctions. As such, the provisions at issue are clear and unambiguous and reference to economic realities is not warranted. See Shell Canada Ltd. v. Canada, [1999] 3 S.C.R. 622, at para. 40.
[35] It would be open to Parliament to provide for a broadened definition of sale for the purpose of applying the incentives with clear language to that effect. Given, however, the provisions merely refer to sale, it cannot be concluded that a definition other than that which follows from common law and sale of goods legislation was envisioned.
[36] For the taxation years in issue, approximately 75 per cent of the asphalt produced by the Will-Kare's plant was supplied in connection with Will-Kare's paving services. Thus the plant was used primarily in the manufacturing or processing of goods supplied through contracts for work and materials, not through sale. Property in the asphalt transferred to Will-Kare's customers as a fixture to real property.
[37] The principles enunciated in Crown Tire and Hawboldt Hydraulics, to the extent they dictate reference to a common law and statutory definition of sale, offer a guide preferable to the broader interpretation of sale described in Halliburton and Nowsco.

The SCC effectively confirmed that, in determining if there is manufacturing or processing of goods for sale for purposes of the Act, reference is to be made to the sale of goods legislation and common law and further that manufactured or processed goods supplied through contracts for work and materials are not sold to the customer. More specifically, the SCC cited Crown Tire's approach at 6471 distinguishing a contract for sale from a contract for work and materials:

[21] The Crown Tire case related to whether the application of treads manufactured by the taxpayer to tires brought in by customers for repair constituted the manufacture or processing of goods for sale. Strayer, J. (later J.A.) disallowed the taxpayer's claim to the s. 125.1 manufacturing and processing profits deduction as the manufactured tread was supplied through a contract for work and materials, a characterization based upon the method through which property transferred to the buyer. See p. 223:

In Benjamin's Sale of Goods (London, 1974), in considering the distinction between a contract of sale of goods and a contract for work and materials, it is stated:

Where work is to be done on the land of the employer or on a chattel belonging to him, which involves the use or affixing of materials belonging to the person employed, the contract will ordinarily be one intended for work and materials, the property in the latter passing to the employer by accession and not under and contract of sale. In our view, the majority decision in Will-Kare clarified that "sale" for M & P purposes is to be interpreted in its legal sense as suggested by the Crown Tire case rather than in the broader sense found in the Nowsco and Halliburton cases. Accordingly, the issue in XXXXXXXXXX's situation is whether its contracts are for sale of goods, with "sale" being interpreted in the legal sense as suggested in Will-Kare, or whether property in its fabricated products passes to its the customers by accession under a contract for work and materials.

It is a question of fact whether the products fabricated by XXXXXXXXXX pass to its customers by accession or by sale. The documentation and the details of information provided in your referral are not sufficient for us to make a determination as to whether XXXXXXXXXX's shop expansion and XXXXXXXXXX are primarily used to manufacture products for "sale." Accordingly, we offer the following comments for your guidance in the determination.

To determine whether XXXXXXXXXX's shop expansion and XXXXXXXXXX are primarily used to manufacture or process goods for sale, one would have to review the extent to which the activities for which the shop expansion and XXXXXXXXXX are used are in fact manufacturing or processing. The meaning of "manufacturing" and "processing" are explained in paragraph 3 of IT-145R (Consolidated), Canadian Manufacturing and Processing Profits - Reduced Rate of Corporate Tax.

In addition, one would have to determine the proportions of the goods manufactured or processed that are transferred to customers by sale and by accession under contracts for work and materials and then relate these proportions to the manufacturing or processing usage of the shop expansion and XXXXXXXXXX in order to ascertain that the "primarily" requirement in paragraph (c) of the definition of qualified property in subsection 127(9) is met. In this regard, "sale" would have to be interpreted in accordance with the SCC decision in Will-Kare, namely by taking into account the applicable provincial sale of goods legislation and common law.

To determine the proportion of goods for sale, one cannot simply rely on XXXXXXXXXX's proportion of total revenue that is represented by the revenue from contracts identified as being for the sale of goods, as opposed to revenues from contracts for work and material or strictly for maintenance. For instance, if XXXXXXXXXX were to use its shop and XXXXXXXXXX solely to manufacture or process goods that are transferred to customers by sale but the revenue therefrom accounts for only, say, 20% of the taxpayer's total revenues, in our view, the shop and XXXXXXXXXX would meet the primarily used for manufacturing or processing goods for sale requirement for ITC purposes.

Ideally, each contract should be reviewed to determine whether it is for the sale of goods or for work and materials or at least such number of contracts should be reviewed as it would be sufficient to conclude that the "primarily" requirement mentioned above is or is not met. Based on the breakdown of the contracts in paragraph 9 above, we presume that you have accepted that the "fabrication" contracts are for the sale of goods and that the "installation" contracts are simply for service (or for work and materials). Therefore, it would appear that the hurdle lies in the proper classification of XXXXXXXXXX's "fabrication and installation" contracts.

The courts have been asked many times for a determination as to whether a contract was one for the sale of goods or for work and materials. The indicia considered by the courts include the following:

1. the intention of the parties;

2. the substance (or principal component) of the contract;

3. the actual and primary role of taxpayer;

4. the subject matter of the transaction (primary versus incidental); and

5. the ownership of the goods.

The intention of the parties must be ascertained through a review of the contract documents, including any ancillary documents leading to the final contract, and the industry practice. In XXXXXXXXXX's case, it would not be appropriate to simply limit oneself to a review of the PO's. In order to ascertain the intention of the parties, it is necessary to also consider the customers' requests for a bid from XXXXXXXXXX and XXXXXXXXXX's quotes (as well as any other pertinent communication between the parties).

In determining whether or not a taxpayer's particular contract is for the sale of goods, one would have to take into account the value of the product being transferred to a customer relative to the value of the total contract as well as the intention of the negotiating parties and the primary role of the taxpayer.

In Preload Company of Canada Ltd, (1958) 13 D.L.R. (2d) 305, a decision of the Saskatchewan Court of Appeal (later affirmed by the Supreme Court of Canada), a contract for the manufacture and delivery of prestressed concrete pipe was held to be a contract for the sale of goods. In Preload, the Court indicated that the determination rests on the "essential character of the agreement" and ruled that if the contract was "substantially" (measured in that instance in terms of the contract value) for materials rather than skill, the contract was for one for the sale of goods. Conversely, it follows that if the contract was substantially for skill, the contract was for work, materials and labour. Speaking for the Court, Culliton J.A. said at pages 313-314:

Whether a contract is one for the sale of goods, or is one for work and wages depends upon the essential character of the agreement. If the City was to pay substantially for materials rather than skill, then the contract was one for the sale of goods. Notwithstanding that a high degree of skill goes into the making of the pipe, if such skill is primarily for the purpose of producing pipes for delivery to the City at a price, then the contract is one for the sale of goods: J. Marcel (Furriers) Ltd. v. Tapper, [1953] 1 All E.R. 15; Cheshire & Fifoot, Law of Contract, 3rd ed., pp. 162-3; Benjamin on Sale, 7th ed., pp. 166 et seq.; Robinson v. Graves, [1935] 1 K.B579; Lee v. Griffin (1861), 30 L.J.Q.B. 252; and Clay v. Yates (1856), 1 H. & N. 73, 156 E.R. 1123.

If a customer asked XXXXXXXXXX for a bid to supply and install, say, a XXXXXXXXXX meeting certain specifications and the value of the XXXXXXXXXX is substantially more than the value of the installation, there is a likelihood that the contract is for the sale of the XXXXXXXXXX (as opposed to a contract for work and material), with installation being ancillary to the sale, even if the related PO simply states "fabricate, supply and install."

In determining whether or not a contract is for the sale of goods, the point in time when ownership of the product passes to the customer is an important consideration. In addition to the contract itself, evidence of the transfer of ownership may also be found in insurance contracts covering risk of loss or damage. If ownership passes to the customer prior to the installation, then this would be one factor pointing to a contract for the sale of goods. Contrary to XXXXXXXXXX's position, we believe that the principles in Will-Kare are applicable in XXXXXXXXXX's situation. We do not find persuasive that the determination of whether a product passes to a customer by a contract for work and materials or by sale turns necessarily on whether the product manufactured, fabricated or produced is a "discrete and identifiable good". XXXXXXXXXX's position seems to suggest that there continues to exist the two lines of authorities represented by Crown Tire and Hawboldt on one hand, and Nowsco and Halliburton, on the other hand, even after the Will-Kare decision. In our view, the SCC decision in Will-Kare provides authority for challenging M&P claims in Nowsco, Halliburton and other similar situations. However, we would mention that the fact that a taxpayer's product is a "discrete and identifiable good" would be a factor in the evaluation and classification of the related contract between a contract for the sale of goods and a contract for work and materials. Furthermore, contrary to XXXXXXXXXX's position, in our view the form of the contract is important in establishing whether a contract is one for the sale of goods or one for work and material. As indicated in Will-Kare, instead of having one contract for work and materials, a taxpayer could arrange to have two contracts, one for the sale of the product and one for installation. The tax consequences generally apply to the transactions as completed by the taxpayer and not as the taxpayer could have completed them.

In your referral, you conclude that the shop expansion and XXXXXXXXXX are not eligible for ITC because of the similarity between XXXXXXXXXX 's situation and the situation in Will-Kare:

In the case at hand there are parallels between Will-Kare and XXXXXXXXXX. Both Will-Kare and XXXXXXXXXX expanded their business operations vertically. For example, Will-Kare expanded operations to include the manufacture of asphalt to supply their paving business. Before Will-Kare constructed the asphalt plant they purchased asphalt from 3rd parties. Similarly, XXXXXXXXXX expanded operations to include the fabrication of equipment to supply their installation crew. Before XXXXXXXXXX constructed the fabrication shop they installed machines and equipment supplied by 3rd parties. Will-Kare's paving contracts were for the supply and installation of asphalt. Will-Kare did not have separate contracts for the sale of asphalt, and for the installation of asphalt. Similarly, XXXXXXXXXX does not have separate contracts, or PO's, for the fabrication of machines and equipment and the installation of machines and equipment. Accordingly, we submit that the shop is not used to manufacture 'goods for sale', but rather is used to fabricate goods supplied in connection with a service, i.e. the installation of the goods. In a small number of cases XXXXXXXXXX has fabricated something but did not complete the installation. However, it is more common that jobs involving fabrication also include the installation of the equipment. It is also common for a job to include installation of equipment that was not fabricated by XXXXXXXXXX.

As explained above, we are unable to conclude as you have because of lack of adequate information. Assuming that XXXXXXXXXX's activities carried on in the shop expansion and for which the XXXXXXXXXX are used constitute manufacturing or processing, it would appear that the conclusions concerning XXXXXXXXXX's eligibility for the ITC rests on the classification of the "fabrication and installation" contracts as between contracts for the sale of goods and contracts for work and materials. It is a question of fact how these contracts should be classified. In making the classification, the factors and comments above should be taken into account.

We would be pleased to offer assistance in the review of specific contracts and other documentation you may wish to forward to us.

S. Parnanzone
For Director
Business and Partnerships Division
Income Tax Rulings Directorate
Legislative Policy and Regulatory Affairs Branch